OSHA Inspection: ALLIED SIGNAL

Issued

Apr 21, 1993

Abate by

May 24, 1993

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not furnish employment and a place of employment which
were free from recognized hazards that were causing or likely to cause
death or serious physical harm to employees in that employees were
exposed to:  the hazard of a runaway reaction and uncontrolled release
of confined gases and reactants:
a)  On or about 11/9/92 one research technician was seriously hurt
during a step in the pilot production of DMHA (dimethyl hydroxyl
amine).  During the quaternization step of the process in a 30 gallon
reactor vessel, a sudden unexpected pressure rise resulted in the
rapid uncontrolled release of confined gases.  This event resulted
in the attending technician suffering a broken arm.
The employer did not adequately investigate or otherwise account for
the effect of the separation and  neutralization on the thermal
sensitivity
of O-MBDO and any possible subsequent effect on the quaternization
phase of the DMHA process prior to its use in a pilot plant production
level reaction.
b)  The most appropriate methods were not utilized to safely heat the
O-MBDO and dimethyl sulfate mixture thereby increasing the risk of a
runaway exothermic reaction during the quaternization phase of the pilot
plant DMHA production.
Among other methods, feasible and acceptable abatement methods to
correct the hazard include:
1.  Conduct a complete stability and process hazard analysis of the
quaternization phase of DMHA production.  This analysis must
account for the effects of isolation and neutralization and
subsequent use of "acidwashed" O-MBDO in the quaternization
phase of DMHA production.
2.  Completely re-evaluate the way the O-MBDO/DMS mixture is heated,
with appropriate consideration given to its "strong exothermic
reaction" and with emphasis on the use of the safest heating method
available, e.g. hot water bath.
Ref:  Discussion Section of Dust-Tech Inc. 1992
Report Section "D".